ML18150A023
| ML18150A023 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/08/1987 |
| From: | STEWART W L VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 87-126, NUDOCS 8704140061 | |
| Download: ML18150A023 (3) | |
See also: IR 05000281/1986036
Text
,, * VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W*. L. STEWART VICE PRESIDENT
NucLEAB OPERATIONS
April 8, 1987 U. S. Nuclear Regulatory
Commission
Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 NRC INSPECTION
REPORT NO. 50-281/86-36
Serial No.: NO/WDC:pms
Docket No.: License No. : 87-126 50-281 DPR-37 We have reviewed your letter of March 2, 1987, in reference
to the inspection
conducted
at Surry Power Station on November 13-20, 1986 and February 9, 1987 and reported in Inspection
Report No. 50-281/86-36.
Based on our review, we have determined
that we are in compliance
with 10 CFR 50 Appendix J and our Technical
Specifications.
Our response to the Notice of Violation
is addressed
in the attachment.
We have no objection
to this inspection
report being made a matter of public disclosure.
If you have any further questions, please contact us. v(\Yt~;::rs, ~.j . -. ', *' "" '°'-' W. L. Stewart Attachment
cc: U. S. Nuclear Regulatory
Commission
101 Marietta St., N.W. Suite 2900 Atlanta, Georgia 30323 Mr. w. E. Holland NRC Senior Resident Inspector
Surry Power Station 61 870408 870414AODOOCK
05000281 PDR PDR G ,,<fro I y dt
\ * NRC COMMENT: RESPONSE TO NOTICE OF VIOLATION
ITEM REPORTED DURING NRC INSPECTION
CONDUCTED
ON NOVEMBER 13-20, 1986 AND FEBRUARY 7, 1987 INSPECTION
REPORT NO. 50-281/86-36
During the Nuclear Regulatory
Commission (NRC) inspection
conducted
on November 13-20, 1986 and February 9, 1987, a violation
of NRC requirements
was identified.
The violation
involved failure to properly establish
conditions
to perform the Type A ILRT. In accordance
with the "General Statement
of Policy and Procedure
for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C (1986), the violation
is listed below: 10 CFR 50 Appendix J, Paragraph
II defines a Type A test as a test intended to measure the primary containment
overall integrated
leakage rate obtained by a summation
of leakage through all potential
leakage paths including
valves, fittings, and components
which *penetrate
containment.
Paragraph
III.A.1.(d)
requires that fluid systems that are part of the reactor coolant pressure boundary and are open directly to the containment
atmosphere
under post-accident
conditions
shall be opened or vented to the containment
atmosphere
prior to and during the Type A test. All vented systems must be drained of water to the extent necessary
to assure exposure of the containment
isolation
valve to containment
air test pressure and to assure they will be subjected
to the post-accident
differential
pressure.
Systems that are normally filled with water and operating
under post-accident
conditions
are not required to be vented; however, their containment
isolation
valves must be Type C tested. Paragraph
III.C requires that containment
isolation
valves be Type C tested to measure their leakage rate by pressurizing
with air or nitrogen unless the valve is pressurized
with fluid from a seal system. Technical
Specification, Table 3.8-2, lists the containment
isolation
valves and specifies
which ones are exempt from Type C testing. Such exemption
signifies
that the valves have received credit for a water seal and are not considered
a credible leakage path for the containment
atmosphere.
Table 3.8-2 includes the isolation
valves for Penetrations
No. 46, 63, 64, and 66 through 71 and does not exempt them from Type C testing. Contrary to the above the licensee failed to either properly vent and drain Penetrations
No. 46, 63, 64, and 66 through 71 during the performance
of the November 1986, Type A test on Unit 2, or to determine
the overall integrated
leakage rate by the summation
of the leakages obtained during the Type C testing of such penetrations
to the results obtained during the CILRT. This is a Severity Level IV violation (Supplement
I).
r ~-RESPONSE:
1. Admission
or denial of the alleged violation:
The alleged violation
as stated is not correct. The notice of violation
indicates
that any penetration
listed in Table 3.8-2 of the Technical
Specifications
subject to Type C testing must also be vented and drained during the Type A test. Such a requirement
is not found in either 10 CFR 50 Appendix J or the Technical
Specifications.
Paragraph
III.A.l.(d)
of Appendix J states that systems normally filled with water and operating
under post-accident
conditions
need not be vented; however their containment
isolation
valves must be Type C tested. The containment
testing of Unit 2 was in compliance
with this requirement.
The penetrations
specified
in the notice of violation
(46, 63, 64, 66, 67, 68, 69, 70, and 71) would be normally filled with water and operating
under post-accident
conditions.
Accordingly, Type C tests were performed
prior to the ILRT on each of the corresponding
containment
isolation
valves, and the penetrations
were not vented for the Type A test, in accordance
with the approved test procedure.
A complete list of containment
penetrations, their status during the ILRT, and an explanation
of their status was included in Attachment
7.7 of the "Reactor Containment
Building Integrated
Leakage Rate Test" Report for Unit 2, submitted
on March 30, 1987. In response to the NRC Inspector's
concern with the status of the above penetrations
during the Type A test, the final test report also included a review of the test results with the Type C leakages from these penetrations
added to the Type A results. As noted in Attachment
7.8 of the report, the penalty from these Type C leakages was 0.0013 wt percent per day. This would raise the overall calculated
Type A leakage to .065 wt percent per day, well within the allowable
limit of .075 wt percent per day. Since the tests were conducted
in accordance
with the explicit requirements
of the Technical
Specifications
and Appendix J, the ILRT is c.onsidered
to be acceptable, and no corrective
action is deemed necessary.
2. Reason for the violation:
Not applicable.
3. The corrective
steps that have been taken and the results achieved:
Not applicable.
4. The corrective
steps that will be taken to avoid further violations:
Not applicable.
5. The date when full compliance
will be achieved:
Not applicable.